On December 8, 2025, the Commodity Futures Trading Commission launched a supervised pilot that permits selected digital assets and tokenized real-world assets to serve as customer margin in U.S. derivatives, as detailed in Press Release 9146-25. The CFTC framed the program as a controlled experiment to integrate digital collateral while preserving oversight and customer protections.
Pilot design and operational guardrails
The initiative establishes a limited, monitored framework that initially allows Futures Commission Merchants to accept a defined set of digital assets and tokenized RWAs as customer margin on a temporary basis. Participation begins with an initial three-month phase restricting eligible collateral to the pilot’s specified cryptocurrencies and stablecoin, and the CFTC’s Market Participants Division issued a no-action position enabling FCMs to proceed under those conditions.
FCMs joining the pilot must meet prescriptive operational controls and reporting obligations. They must implement AML programs, maintain custody and disclosure protocols, satisfy margin adequacy and capital rules specified under § 1.17(h) and (c)(2)(i), and deploy risk-management procedures tailored to digital asset custody. The program also requires weekly reporting that separates customer holdings across the three customer account classes and rapid escalation of material operational or systemic incidents. The agency positioned the pilot as part of a broader “Crypto Sprint” launched in August 2025 and linked recent regulatory cleanup — including the April 2025 removal of certain outdated crypto-derivatives advisories — to enabling legislation referenced by the release.
The no-action relief is conditional on strict operational readiness before any FCM may hold these assets. Custodial segregation, transparent disclosure to customers, and ongoing capital and margin compliance are mandatory before an FCM may hold non-security digital assets for customers or retain payment stablecoins in segregated accounts. The reporting cadence and account separations are designed to give regulators near-term visibility into exposures, settlement flows and potential contagion channels across customer classes.
From an infrastructure and operations standpoint, the pilot forces reconciliation between traditional clearing processes and blockchain-native mechanics. Firms will need audited custody architectures, reconciled ledgers for tokenized RWAs, and incident-response plans that translate blockchain events into cleared-margin actions.
Market reaction and governance concerns
Market participants have begun planning operational integrations tied to the pilot’s parameters. One firm cited in industry filings is preparing a USDC collateral roadmap with a central counterparty partner and a target operational rollout in 2026. Major industry firms publicly endorsed the move as a regulatory unlock for faster, lower-friction settlements and improved capital efficiency, while advocacy groups raised governance concerns. An advocacy organization flagged potential conflicts of interest involving the agency’s acting leadership and urged heightened scrutiny before expanding the program.
The pilot represents a calibrated step toward institutional use of digital collateral in cleared derivatives. The next verified milestone will be the initial three-month reporting window for participating FCMs and the operational rollouts tied to market participants’ USDC integration plans in 2026; those results will determine whether the experiment scales.